Switzerland launches its beneficial ownership register: what compliance teams need to know

On 1 October 2026, Switzerland launched a centralised federal register of beneficial owners. For a country whose name has been synonymous with financial discretion for generations, this is a material shift. More than 500,000 Swiss companies are now subject to new reporting obligations under the Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners, known by its German acronym TJPG. The register went live last week. Its implications for compliance teams conducting due diligence on Swiss entities are immediate.

What the register does and does not do

The Transparency Register is maintained by the Federal Office of Justice and is not publicly accessible. Access is restricted to Swiss authorities and AML-regulated financial intermediaries and advisers for KYC purposes. Switzerland has chosen a model that widens visibility for investigations and compliance purposes without creating a fully public register, a deliberate design choice that reflects the political balance struck during parliamentary debate.

The register covers corporations, limited liability companies, cooperatives, and certain trust structures. Where a trust holds an interest in a reporting entity, the beneficial ownership analysis must assess the trust structure to identify the ultimately controlling natural persons. Foreign legal entities with a Swiss nexus are also in scope. Listed companies whose shares are fully or partially traded on a stock exchange, along with their majority-owned subsidiaries, sole proprietorships, partnerships, and public law entities are exempt.

Companies must report the identity of their beneficial owners, the nature and scope of their control, and any changes within one month of those changes occurring. The register is based on self-declaration and supplements rather than replaces existing due diligence obligations.

Filing deadlines for existing companies

The register opened on 1 October 2026 but existing companies have staggered transitional deadlines running into 2027. Stock corporations subject to ordinary audit must file by 1 January 2027. Other entities subject to ordinary audit have until 1 February 2027. Stock corporations not subject to ordinary audit must file by 1 March 2027. All other legal entities, including foreign entities with a Swiss nexus, have until 1 April 2027. Companies where all beneficial owners are already entered in the commercial register as shareholders or members of a governing body have until 1 October 2028. New companies formed after 1 October 2026 must report within one month of their commercial register entry.

Any commercial register filing made after 1 October 2026 accelerates the reporting deadline to one month from that filing. Companies with upcoming commercial register changes should treat the TJPG obligation as immediately triggered.

What the revised AMLA adds

Running alongside the TJPG is a revised Anti-Money Laundering Act, also effective 1 October 2026. This extends AML due diligence requirements to certain advisory activities previously outside the AMLA's scope, specifically certain services involving real estate transactions and the formation or structuring of legal entities. The advisers now caught include lawyers, notaries, fiduciaries, and certain trust and company service providers.

The Swiss Parliament adopted the TJPG on 26 September 2025 following sustained international pressure on corporate transparency. FATF's 2016 mutual evaluation rated Switzerland partially compliant on Recommendations 22 and 23, which require designated non-financial businesses and professions to be subject to customer due diligence and suspicious activity reporting obligations. The revised AMLA addresses those gaps directly by extending due diligence obligations to certain advisers. The absence of a centralised beneficial ownership register was a known structural gap relative to FATF standards. Switzerland's next 5th round mutual evaluation is scheduled for 2027/2028, and the TJPG is timed to demonstrate that gap has been closed ahead of that assessment.

What this means for compliance teams conducting due diligence on Swiss entities

Switzerland's beneficial ownership transparency risk profile has changed. A compliance programme that assessed Swiss counterparties or investment structures under the pre-October 2026 framework is working from an outdated picture.

The practical implications are specific. Financial intermediaries with access to the register now have a new verification channel for Swiss entity ownership that did not exist last month. CDD processes for Swiss corporate counterparties should be updated to reflect that the register exists and that a failure to consult it, where access is available, may raise questions about the thoroughness of the due diligence conducted. For entities not yet registered under the transitional deadlines, compliance teams should document how they are managing the gap between the register's effective date and the entity's filing deadline.

The broader country risk picture is also shifting. Switzerland sits within a global trend of tightening beneficial ownership transparency, alongside the EU's AMLA beneficial ownership database, Singapore's post-2023 corporate service provider reforms, and Australia's Tranche 2 reforms bringing trust and company service providers into AML scope. The US domestic BOI exemption remains the significant outlier, a point covered in an earlier KnowYourCountry newsletter. Switzerland's register moves the country from a known structural gap to a materially stronger position on one of FATF's core transparency expectations.

At KnowYourCountry, beneficial ownership transparency is a dedicated category within our country risk methodology. Our assessments across 245 jurisdictions are updated as material regulatory changes take effect. Switzerland's TJPG represents exactly the kind of framework-level change that moves a jurisdiction's risk profile, and our methodology has been built to capture it. Our enhanced country reports give compliance teams the jurisdiction-level detail they need to reflect changes like this in their own CDD and risk assessment processes. It is a methodology trusted by regulated businesses and government agencies for over 20 years.